Responsible Drilling Alliance
                            Action Flash!
                 RDA joins Clean Air Council
                       with an urgent request!

RDA joins our friends at Clean Air Council in the following request: 

  Dear Friend, 

 

  PA DEP is proposing to finalize permit exemptions on gas drilling and well

  completion equipment for the shale gas industry!  

 

  PA DEP recently announced that they intend to finalize guidance 

  that would exempt gas companies from permitting for flaring and emissions  

  released from storage tanks and wells.  

 

  This guidance will have a detrimental impact on local and regional air quality if it

  is finalized as is. PA DEP needs to hear what local shalefield residents and other    

  concerned PA residents think about these additional permit exemptions to the  

  industry.

 

  Without your comment, this guidance will be finalized as it currently stands. This is  

  your chance to tell PA DEP what you think about the proposed exemptions. 

 

  Thank you for helping to protect everyone's right to breathe clean air!


    Matt Walker 
    Clean Air Council

 
  Submit written comments, suggestions or 
  objections to:

Krishnan Ramamurthy
Environmental Program Manager
Division of Permits
Bureau of Air Quality, 12th Floor
Rachel Carson State Office Building
P.O. Box 8468
Harrisburg, PA 17105-8468

  or send by email to: [email protected]

  Written public comments must be submitted to the Department no later than
  March 19, 2013.
Comments received by facsimile will not be accepted.

  Use major talking points from the letter below, excerpted from the Clean Air  
  Council's suggested comments, to write your own letter to PA DEP:

    

DEP's proposed modifications to the exemption list for oil and gas air pollution sources will have a major impact on local air quality and public health. The public needs more protections from harmful air pollutants - not less. 


DEP has proposed twice over three years to limit exemptions for the shale gas industry; they are now ignoring many of those proposed exemptions. I urge PA DEP to do its job of protecting public health and air quality by removing all proposed permit exemptions related to oil and gas wells and storage tanks. 

In light of upcoming technology requirements for flaring, I request that PA DEP explain the justification, from a public health and legal perspective, behind exempting all flaring at gas wells from permitting at this time. How will these exemptions better protect public health? First, I insist that PA DEP incorporate green completion requirements before EPA's Oil and Gas standards are required in 2015. If flaring will be allowed to continue until that time, I urge the Department to continue to include the originally proposed 14 day limitation on flaring. It appears as though PA DEP is attempting to allow flaring with no permits, including enclosed flaring, flaring for re-fracking, and flaring for exploratory wells, after the 2015 standards are supposed to be implemented. 

DEP should now clarify how this exemption guidance works with the new General Permit 5, and ensure that it does not preclude companies from obtaining proper permits. The GP-5 currently requires permits for flares, and this guidance appears to eliminate that requirement. 

PA DEP should also add specific language that does not exempt flares at synthetic minor sources of air pollution, those that are very close to tripping the major source threshold, especially for the purposes of analyzing aggregation, and wells associated with major sources. Emissions from well pads can add up quickly, especially in conjunction with other facilities like compressor stations. The proposed permitting exemption will exempt wells that normally would have to be counted in determining whether facilities or equipment should receive a major source permit. This could result in inaccurate permit decisions for oil and gas facilities. I urge PA DEP to remove the exemption for wells that would fall under this category.

I am very concerned that DEP is now exempting non-road engines, including drill rig engines, from air pollution permits, rather than continuing to require companies to obtain the GP-11 permit. I request that PA DEP explain the reasoning behind this decision and remove this exemption from this guidance.

The exemptions include very little specifics on how accurate air monitoring would be accomplished at well sites and storage facilities. I urge DEP to include stringent air monitoring requirements in this guidance, such as requiring FLIR detection at well sites and storage tanks every three months as equipment can deteriorate over time, or stop functioning correctly without proper maintenance. In addition, PA DEP should require a company that detects a leak to repair it within 2 weeks after initial detection. 

Thank you for considering my comments and please keep me apprised of any responses related to this proposed guidance.